3. Substantial Contribution to Resolution of Issues

A party may make a substantial contribution to a decision in one of several ways.⁴ It may offer a factual or legal contention upon which the Commission relied in making a decision,⁵ or it may advance a specific policy or procedural recommendation that the ALJ or Commission adopted.⁶ A substantial contribution includes evidence or argument that supports part of the decision even if the Commission does not adopt a party's position in total.⁷

Greenlining/LIF, representing low-income ratepayers, substantially contributed through its recommendations on energy efficiency and CARE issues. Greenlining/LIF recommended that the Commission leverage energy efficiency dollars through LIHEAP providers including utility company purchases of energy efficient equipment, utility contracts with a LIHEAP agency for LIEE programs, and a coordinated program between a utility and LIHEAP agency for a neighborhood within a utility service territory. We adopted these recommendations subject to the caveat that the customers are those subject to Commission jurisdiction and not public agency utilities.

In its comments on D.01-05-033, Greenlining/LIF recommended a capitation fee for community organizations, and the initiation of meetings through the Energy Division between energy utilities. We adopted both of these recommendations and recognize the substantial contribution by Greenlining/LIF on these issues. While we did not adopt all of Greenlining/LIF's proposals, we profited by its participation and comments on issues affecting low-income customers and recognize its substantial contribution to D.01-05-033.

In D.01-06-010 we discussed the proposals of Greenlining/LIF and our adopted responses. Although Greenlining/LIF requested an increase in the CARE discount from 15% to 25%, after weighing all of the factors we provided for an increase in the CARE discount of 20% for both electric and gas usage. In adopting this increase, we considered the arguments of Greenlining/LIF for a greater increase, and Greenlining/LIF substantially contributed to our adopted position. Similarly, Greenlining/LIF recommended relaxing the CARE eligibility criteria from 150% to 175% of Federal Poverty Guidelines, which we adopted in our decision. Overall we adopted many of Greenlining/LIF's proposals for low-income customers, and we believe it made a substantial contribution to D.01-06-010.